UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON , D . C . 20460

Mr. Marc Gross Fireaway Inc . 5852 Baker Road Minnetonka, MN 55345 

## / JUt 1 

## 5 2013 O FFI CE O F AI R A N D RAD IAT I ON

Re: Incomplete SNAP Submission for Stat-X/Aero-K Condensed Aerosol System in Fire Suppression Dear Mr. Gross: Thank you for Fireaway Inc.'s submission to the Environmental Protection Agency (EPA). EPA established the Significant New Alternatives Policy (SNAP) program to implement section 612 ofthe Clean Air Act. Your application received on May 23,2013 has been reviewed for completeness as part ofthe initial SNAP review. We have found the submission to be incomplete. The following information is necessary in order to allow the Agency to continue the review ofFireaway Inc.'s submission for Stat-X/Aero-K Condensed Aerosol System in fire suppression in normally occupied areas. 1 . Application CBI Claims. Please provide a public version of your initial application in which all confidential business information (CBI) is removed . We will need a version with all CBI removed to place in the public docket. Also, please substantiate your CBI claims. 2 . Use Information. In Part I, Number 4, Part A, you state that Stat-X will be used in normally occupied and normally unoccupied areas (shipboard machinery spaces, marine engine compartments, electrical cabinets, engine compartments, turbine enclosures, flammable liquid storage, remote cellular base stations). a. Please specify the normally occupied spaces in aircraft, ships , and vehicles for which Stat-X is proposed for use. Please also include the approximate minimum and average dimensions ofthese spaces , and anticipated rate of airflow in spaces where you propose to use Stat-X. b. In Part II, Section D, Number 3, you state that Stat-X systems are mounted in a distributed layout throughout the protected space. Please provide a description of the layout, including the number of generators included, where the generators will be located (e.g ., ceiling, walls), approximate distance between generators , and the direction ofthe generator nozzles.

I nte rn et Add ress (URL) • http :// www.epa . gov Recy c l e d/Recy c l a b l e · Pri nted with Veg etab le Oi l Ba sed I nks o n 100 % P ost co ns um e r. P rocess Ch l ori n e F re e Recycl ed Paperc. In Attachment 1, you indicate that Stat-X generators used in unoccupied spaces are triggered by thermal or electrical activation, depending on the model. Please clarify whether generators proposed for occupied spaces will rely on a manual or electrical discharge system, or both, and specify the release rate ofthe generator (g/sec). 3 . Charge Size. In Part I, B, 2, c, you state that a 500-gram (l.llb) Stat-X generator can be used to protect a 265 ft3 space . Does 500 grams represent the average, minimum, or maximum charge size of a Stat-X generator? In your previous submission for unoccupied space use, you had indicated a standard design concentration of Stat-X generators to not exceed 100 g/m3 and averaging 75 g/m3

. Please confirm ifthese remain the same for the generators used in occupied spaces. 4. Particle Size. In your previous submission for use in unoccupied spaces, you had indicated that the post activation product ofthe Stat-X generator is 30 percent gaseous and 70 percent particulate, and therefore the amount ofparticulate matter in the air could reach 70 g/m3

. You had also indicated that 97 percent ofthe particulate matter is less than 5 J.lm and 76 percent is less than 3 J.lm. Please confirm that these are the particle sizes produced by the Stat-X generators used in occupied spaces. 5. Safety Precautions. In your submission you state that discharge of Stat-X in occupied spaces reduces visibility in the protected space. In Part I, Section B, Number 1 , your submission notes that NFP A 201 0 presents several approaches to facilitate safe egress of personnel. a. Specifically, what training; installation, use, and disposal guidelines; or other precautions will be provided for Stat-X generators? Please provide copies of any guidance. b. What is your estimate ofthe maximum egress time expected in situations where visibility is reduced in the protected space? Depending on your response to this question, we may request further information. 6. CBI Claims for Additional Information. If you wish to claim any ofthe information submitted in response to the requests above as CBI, please provide two copies of your response, one containing CBI and one with CBI removed. Here is a summary of information concerning your submission: Substitute name: Stat-X/Aero-K Condensed Aerosol System Substance(s) the substitute will replace : Halon 1301 Sector: Fire Suppression End-uses: total flooding applications in normally occupied and normally unoccupied areas New or retrofit usage: New Date received : May 23, 2013 Status of submission : IncompleteResponses to these questions are necessary for us to begin our review. The information can be submitted via electronic mail or hard copy. If you have questions about your submission, please contact me at (202) 343-9445 or vondemhagen.rebecca@epa.gov . Sincerely, Rebecca von dem Hagen Alternatives and Emissions Reduction Branch Stratospheric Protection Division